Along with Baker v. Carr (1962) and Wesberry v. Sanders (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. Whether the apportionment of Alabama's representative caused the voters to be unequally represented to such a degree that their 14th Amendment rights were violated. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . In dissent, Justice John Marshall Harlan II wrote that the majority had chosen to ignore the language, history, and original intent of the Equal Protection Clause, which did not extend to voting rights. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. In Connecticut, Vermont, Mississippi, and Delaware, apportionment was fixed by the states' constitutions, which, when written in the late eighteenth or nineteenth centuries, did not foresee the possibility of rural depopulation as was to occur during the first half of the century. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. Create an account to start this course today. It was also believed that the 14th Amendment rights of citizens were being violated due to the lack of apportioned representatives for each of the legislative districts. There must be a causal connection between the injury and the conduct brought before the court. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Can a state use a reapportionment plan that ignores significant shifts in population? It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. Voters from Jefferson County, Alabama challenged the apportionment structure of their State House and Senate, which required each county to have at least one representative, regardless of size. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. The Court then turned to the equal protection argument. Other articles where Reynolds v. Sims is discussed: Baker v. Carr: precedent, the court held in Reynolds v. Sims (1964) that both houses of bicameral legislatures had to be apportioned according to population. v. Varsity Brands, Inc. A causal connection can be drawn from the injury to another source, 3. Legislators are elected by voters, not farms or cities or economic interests." It should also be superior in practice as well. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. Reynolds v. Sims | Teaching American History The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14th Amendment by weighing some votes higher than another? The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. States may have to balance representation based on population with other legislative goals like ensuring minority representation. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. Amendments Equal protection clause of the U.S constitution. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. The case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution. Argued November 13, 1963. Click here to contact us for media inquiries, and please donate here to support our continued expansion. Reynolds v. Sims (1964) | The Rose Institute of State and Local Government Especially since the right to exercise the franchise in a free and unimpaired manner is preservative of other basic civil and political rights, any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized. For instance, South Carolina had elected one state senator from each county. --Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[11]. Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1963 to 1972Reynolds v. Sims - Significance, "legislators Represent People, Not Trees", The Census, Further Readings, Copyright 2023 Web Solutions LLC. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell Reynolds v. Sims: Supreme Court Case, Arguments, Impact - ThoughtCo united states - Does the Senate violate Reynolds v Sims? - Politics The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Any one State does not have such issues. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. Having already overturned its ruling that redistricting was a purely political question in Baker v. Carr, 369 U.S. 186 (1962), the Court ruled to correct what it considered egregious examples of malapportionment; these were serious enough to undermine the premises underlying republican government. This case essentially set the standard for the notion of one person, one vote and asserted that legislative districts should be apportioned in ways that are very much closely, if not uniform in population. State representatives represent people, not geographic regions. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? He also alleged that by not doing so, the state was denying the voters and residents of his country their full representation under Alabama law, which violated their equal protection rights found in the 14th Amendment. This system failed to take population size into account, leading to huge discrepancies between district . The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. The court held that Once the geographical boundaries of a district are set, all who participate in that election have an equal vote no matter their sex, race, occupation, or geographical unit. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. State legislatures had been reluctant to redistrict[2] because there existed general upper-class fear that if redistricting to meet population changes were carried out, voters in large, expanding or expanded urban areas would vote for confiscatory wealth redistribution[3] that would severely inhibit the power of business interests who controlled state and city governments[4] early in the century. Reynolds was sentenced for polygamy The 1962 Alabama general election was conducted on the basis of the court-ordered plan, which was immediately appealed to the U.S. Supreme Court. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. It is of the essence of a democratic society, Chief Justice Warren wrote. The U.S. Constitution undeniably protects the right to vote. No. Since the ruling applied different representation rules to the states than was applicable to the federal government, Reynolds v. Sims set off a legislative firestorm across the country. and its Licensors Reynolds v. Sims is a case decided on June 15, 1964, by the United States Supreme Court holding that state legislative districts should be made up of equal populations. The Equal Protection Clause of the Fourteenth Amendment requires that representatives in both houses of a States bicameral legislature must be apportioned by population. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. After specifying a temporary reapportionment plan, the district court stated that the 1962 election of state legislators could only be conducted according to its plan. The 14th Amendment requires that a state government treat everyone equally under the law, and is often used by state citizens to sue their government for discrimination and unequal treatment. Before the argument of Reynolds v. Sims was argued and heard by judges, a case known as Baker v. Carr received a ruling approximately two years beforehand. The districts adhered to existing county lines. Within two years, the boundaries of legislative districts had been redrawn all across the nation. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. Representatives shall be apportioned among the several States according to their respective numbers, counting the whole number of persons in each State, excluding Indians not taxed. The Equal Protection Clause of the 14th Amendment mandates that individual states work to provide equal protection, which means that governing occurs without bias and that lone individual differences are unimportant when considering citizens. All rights reserved. To determine if an issue is justiciable, the Court will look at the nature of the issue, and if it is one dealing with the political power of either the executive or legislative branches, and if it is unlikely that a ruling by the courts will settle the issue, then is it a political question and is non-justiciable. To read more about the impact of Reynolds v. Sims click here. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Chief Justice Earl Warren delivered the opinion of the court. All rights reserved. Jefferson County, with a population of more than 600,000 received seven seats in the Alabama House of Representatives and one seat in the Senate, while Bullock County, with a population of more than 13,000 received two seats in the Alabama House of Representatives and one seat in the Senate. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. Before the industrialization and urbanization of the United States, a State Senate was understood to represent rural counties, as a counterbalance to towns and cities. Section 1. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. Box v. Planned Parenthood of Indiana and Kentucky, Inc. Monell v. Department of Social Services of the City of New York, Will v. Michigan Department of State Police, Inyo County v. Paiute-Shoshone Indians of the Bishop Community, Fitzgerald v. Barnstable School Committee. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Amendment by weighing some votes higher than another? In another case, Wesberry v. Sanders, the Court applied the one person, one vote principle to federal districts for electing members of the House of Representatives. Denise DeCooman was a teaching assistant for the General Zoology course at California University of Pennsylvania while she earned her Master's of Science in Clinical Mental Health Counseling from fall semester of 2015 and spring of 2017. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Since under neither the existing apportionment provisions nor either of the proposed plans was either of the houses of the Alabama Legislature apportioned on a population basis, the District Court correctly held that all three of these schemes were constitutionally invalid. The district court had not erred in its finding that neither the Crawford-Webb Act or the 67-member plan could be used as a permanent reapportionment plan, the attorneys argued. In Reynolds v. Sims, the Court was presented with two issues: The Supreme Court held that the apportionment issue concerning Alabama's legislature was justiciable. The U.S. Supreme Court affirmed the district court, holding that the, The District Court for the Middle District of Alabama found that the reapportionment plans proposed by the Alabama Legislature would not cure the. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. Along with Baker v.Carr (1962) and Reynolds v. Sims (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies. This was not an easy ruling - the Court was deeply divided over the issue, and the sentiment was strong for the federal courts to stay out of the state matter. Enrolling in a course lets you earn progress by passing quizzes and exams. This case essentially set the standard for the notion of one person, one vote and asserted that legislative districts should be apportioned in ways that are very much closely, if not uniform in population. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. The Court's decision was among the first to hold that the free exercise of religion is not absolute. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. The reason for a non-population-based Federal Senate has more to do with a compromise that allowed for the creation of a national government. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . It established the precedent that felons are not allowed to vote.B.) Simply stated, an individual's right to vote for state legislators is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State. This system failed to take population size into account, leading to huge discrepancies between district . It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. Requiring states to employ honest and good faith practices when creating districts. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. Spitzer, Elianna. It is known as the "one person, one vote" case. All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Chief Justice Earl Warren delivered the opinion of the court. 2d 506 (1964), in which the U.S. Supreme Court established the principle of one person, one vote based on the equal protection clause of the fourteenth amendment. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill.